Even another logging question...

[Kritchlow]

Scenario..,, and following the flow chart.

First Officer, type rated in the aircraft flying for xxx airlines. He is not the sole manipulator of the controls, but he is willing and able to be PIC should the need arise.
The chart seems to say he can log PIC..?? Am I screwing up the chart???

 

[Greg Bockelman]

As written, you are not screwing up the chart. But it isn’t really correct. It is poorly written. The rated First Officer can only log PIC when s/he is sole manipulator. EdFred’s flow chart shows this better.

 

[midlifeflyer]

I would not assume anyone's chart is correct without verifying it with the regulations. Nothing about logging PIC by being qualified to act as PIC with no other conditions.

 

[Hacker]

Is the flight being operated under Part 121 or Part 91?

What does the FO intend to use the logged time for? (Ergo, to satisfy the requirements for a rating, currency, or a job?)

 

[dtuuri]

The 121 standard is "he who signs for the airplane logs PIC, the other guy(s) don't".

What a brilliant way to log time--as a reflection of reality! I don't see how the PIC time in a pilot's logbook in this day and age says anything at all about the pilot's real experience level. "Steering" is not the same as "commanding". You have to be a lot more skilled than just able to hold a heading to earn command of an aircraft. And SIC time? As a safety pilot? YGBSM.

"O, what a tangled web we weave when first we practise to deceive!" - Walter Scott quote​

 

[Busflyer]

Chart is wrong, Captain is designated PIC.

 

[midlifeflyer]

What a brilliant way to log time--as a reflection of reality! I don't see how the PIC time in a pilot's logbook in this day and age says anything at all about the pilot's real experience level. "Steering" is not the same as "commanding". You have to be a lot more skilled than just able to hold a heading to earn command of an aircraft. And SIC time? As a safety pilot? YGBSM.

"O, what a tangled web we weave when first we practise to deceive!" - Walter Scott quote​

You are assuming it's intended to show a pilot's real experience level as opposed to showing the pilot meets FAA requirements for certificates, ratings, privileges and currency.

Whether the FAA "should" change the rules is a different question. But it's certainly not "deception" to follow rules which have been consistently officially interpreted for at least 40 years. Deception isn't quite the opposite of that, but closer.

 

[midlifeflyer]

Chart is wrong, Captain is designated PIC.

It's a logging chart, not a command chart.

 

[jordane93]

It’s a really weird deal. The FO can log PIC whenever he/she is sole manipulator because he is rated in category, class and type. However the airlines won’t accept this as PIC time even though it’s completely acceptable per the regs.

 

[kayoh190]

It’s a really weird deal. The FO can log PIC whenever he/she is sole manipulator because he is rated in category, class and type. However the airlines won’t accept this as PIC time even though it’s completely acceptable per the regs.

Not just the airlines - I’ve done hiring at both my 91 and 135 jobs, and we never allowed it either. I mean, log whatever the hell you want, but we were clear that any PIC listed on the application needed to be actual command time. I understand the reg, but acting PIC is what everyone is looking for, so that stipulation makes complete sense to me.

 

[MauleSkinner]

Of course, no pilot of a two-pilot airplane is EVER sole manipulator of the flight controls.

 

[MauleSkinner]

It’s a really weird deal. The FO can log PIC whenever he/she is sole manipulator because he is rated in category, class and type. However the airlines won’t accept this as PIC time even though it’s completely acceptable per the regs.

They're obviously (and rightly) looking at ACTING PIC time, not the product of legalistic minds.

 

[dtuuri]

You are assuming it's intended to show a pilot's real experience level as opposed to showing the pilot meets FAA requirements for certificates, ratings, privileges and currency.

You're assuming that's what I assume, but I don't. What I assume is the FAA used to mean for the logbook to reflect reality, so they could tell when the pilot had enough real experience to deserve the advanced credential. Find me somebody in the 1960s who logged PIC time while taking dual instruction for the commercial.

 

[midlifeflyer]

It’s a really weird deal. The FO can log PIC whenever he/she is sole manipulator because he is rated in category, class and type. However the airlines won’t accept this as PIC time even though it’s completely acceptable per the regs.

It's simple and not particularly weird. Any employer, in aviation or out, can create whatever metrics they want to demonstrate the experience they are looking for. You might list your teenage years working the register at McDonalds, but I doubt the accounting firm you apply later to counts it as experience working with numbers.

So, many pilots with career goals separate logged "Part 61 PIC" from acting "Part 1 PIC." But even that doesn't provide a complete solution, because even all "acting" PIC time isn't necessarily a good demonstration of experience.

So no, if they are looking for command experience, they understandably do not care about your safety pilot time in a Cessna 152, even though if you logged PIC, you actually were the Part 1 PIC. OTOH, I suspect they do care about your 50 hours of multi-engine hands-on flying time even though half of it was only "sole manipulator" PIC since insurance required you be with a more experienced pilot on board, so it was not "Part 1 PIC"

I call it the difference between data and presentation. Your logbook is a data collector using the FAA's required columns and whatever additional columns you want to track other things. "Part 1 PIC" vs "Part 51 PIC." >50 NM cross countries toward certificates and ratings vs the shorter ones which also count toward Part 135 minimums. What you present to a potential employer is the data set they want to see.

 

[timwinters]

I think @EdFred just pulled the trigger...

 

[Mooney Fan]

Scenario..,, and following the flow chart.

First Officer, type rated in the aircraft flying for xxx airlines. He is not the sole manipulator of the controls, but he is willing and able to be PIC should the need arise.
The chart seems to say he can log PIC..?? Am I screwing up the chart???

View attachment 71305

He/She can log SIC time

14 CFR FAR Part 61

61.51- Pilots may log as second-in command time all flight time when qualified and occupying a crew member station in an aircraft that requires more than one pilot.

 

[midlifeflyer]

You're assuming that's what I assume, but I don't. What I assume is the FAA used to mean for the logbook to reflect reality, so they could tell when the pilot had enough real experience to deserve the advanced credential. Find me somebody in the 1960s who logged PIC time while taking dual instruction for the commercial.

Times change, rules change, and what the FAA wants to count toward the certificates and ratings they issue also changes.

I did a little research on this while laid up recovering from hip surgery some years ago, and the "modern rule" has its roots in the 1940 CAR. "Logged PIC" was not a concept but "solo" too its place. "Solo" was different than now; it was defined as (ready for this?) "sole manipulator of the controls." Yep. "sole manipulator" was the 1940s measure for meeting some requirements. It was more limited than today - you could only use half of the dual instead of all of it - but the concept was there.

Where I really tend to disagree with others is I just don't see the "moral imperative" - a "right" and a "wrong" - some others seem to in an administrative decision how to count time toward the issuance of certificates, ratings, privileges and currency.

 

[midlifeflyer]

The chart "error" is pretty much here.



Makes it sound like being "willing and able/qualified" are all you need. Kinds of missed the concept of actually doing it. Probably implicit, but this thread demonstrates not necessary understood. A pilot ASEL snoozing in the third row of an A36 may have all the qualifications and may be willing to climb over the seats and help out if asked, but that doesn't let him log PIC time.

 

[Kritchlow]

The chart "error" is pretty much here.

View attachment 71323

Makes it sound like being "willing and able/qualified" are all you need. Kinds of missed the concept of actually doing it. Probably implicit, but this thread demonstrates not necessary understood. A pilot ASEL snoozing in the third row of an A36 may have all the qualifications and may be willing to climb over the seats and help out if asked, but that doesn't let him log PIC time.

But two pilots are not required in an A36..??

 

[Kritchlow]

He/She can log SIC time

14 CFR FAR Part 61

61.51- Pilots may log as second-in command time all flight time when qualified and occupying a crew member station in an aircraft that requires more than one pilot.

The chart makes it look as though they can log PIC time.

 

[jordane93]

Not just the airlines - I’ve done hiring at both my 91 and 135 jobs, and we never allowed it either. I mean, log whatever the hell you want, but we were clear that any PIC listed on the application needed to be actual command time. I understand the reg, but acting PIC is what everyone is looking for, so that stipulation makes complete sense to me.

They're obviously (and rightly) looking at ACTING PIC time, not the product of legalistic minds.

My FO last trip is contemplating taking a job flying a Legacy 600 135/91. Whoever is PF sits in the left seat and the company said he can log PIC due to the sole manipulator rule but he will NOT be the one signing off for the plane and will be SIC. That just doesn’t sit well with me and I told him if he takes the job, I wouldn’t log PIC that way.

 

[midlifeflyer]

But two pilots are not required in an A36..??

But if he climbs over and takes the controls, he can log PIC (sole manipulator). And, in some cases, he might end up being the PIC whether or not he touches the controls.

Trivia: if the A36 happens to be on a passenger-carrying Part 135 IFR flight, it does require two pilots. And anyway, snoozing in the back seat doesn't preclude him from being the pilot in command Yeah, the permutations can get downright silly, but many fall int the "who cares?" column.

 

[midlifeflyer]

My FO last trip is contemplating taking a job flying a Legacy 600 135/91. Whoever is PF sits in the left seat and the company said he can log PIC due to the sole manipulator rule but he will NOT be the one signing off for the plane and will be SIC. That just doesn’t sit well with me and I told him if he takes the job, I wouldn’t log PIC that way.

You certainly have the choice of not logging even if you are clearly allowed to. No one is forcing anyone to count time just because it's legitimate. The only prohibition is logging time which is not legitimate.

 

[dtuuri]

I did a little research on this while laid up recovering from hip surgery some years ago, and the "modern rule" has its roots in the 1940 CAR. "Logged PIC" was not a concept but "solo" too its place. "Solo" was different than now; it was defined as (ready for this?) "sole manipulator of the controls." Yep. "sole manipulator" was the 1940s measure for meeting some requirements. It was more limited than today - you could only use half of the dual instead of all of it - but the concept was there.

You can see, can't you, that this was the first crack at logging the student/instructor relationship? Later, they simply divided it into "Dual" OR "Solo" and had the CFI log all the time as "PIC". Solo became a more accurate description of real command time. Until the 1970s, the types of piloting time loggable were of the either/or variety:

1. PIC (or solo);
2. Second in command;
3. Synthetic trainer; or
4. Flight instruction from...

That's when the wheels came off. The FAA reorganized Part 61 and misplaced the "or" on line 3. Completely changed the meaning and from then on the logging.

 

[midlifeflyer]

You can see, can't you, that this was the first crack at logging the student/instructor relationship? Later, they simply divided it into "Dual" OR "Solo" and had the CFI log all the time as "PIC". Solo became a more accurate description of real command time. Until the 1970s, the types of piloting time loggable were of the either/or variety:

1. PIC (or solo);
2. Second in command;
3. Synthetic trainer; or
4. Flight instruction from...

That's when the wheels came off. The FAA reorganized Part 61 and misplaced the "or" on line 3. Completely changed the meaning and from then on the logging.

I can see a progression and changes. 40 years of consistency is enough evidence to indicate it was intentional. "Wheels come off" is a value judgment I chose not to impose or argue about.

"It confusing and I can't follow it" is a legitimate gripe. Imposing a self-proclaimed quasi-moral "right" and "wrong" is silly.

 

[jordane93]

You certainly have the choice of not logging even if you are clearly allowed to. No one is forcing anyone to count time just because it's legitimate. The only prohibition is logging time which is not legitimate.

Yep. If he does take the job he’ll probably just log it as SIC. He would upgrade in less than a year anyway and the plane only flies 400 hours between 3 crews so he’s not building a whole lot of turbine PIC

 

[dtuuri]

"It confusing and I can't follow it" is a legitimate gripe. Imposing a self-proclaimed quasi-moral "right" and "wrong" is silly.

Not sure if you're saying I'm confused, immoral or both. Misplacing the "or" on line 3 without an NPRM might be immoral if they were trying to sneak in a change without comment, but I just think it was a mistake. It was only after that the Chief Counsel began interpreting when PIC time can be logged. Before then, it was clear.

 

[midlifeflyer]

Not sure if you're saying I'm confused, immoral or both.

None of the above. People have complained about the confusion more or less inherent in the separation of "PIC" into separate "acting" and "logging" concepts. I know you understand those, but it's a legitimate complaint.

I'm only saying "wheels came off" sounds like a "bad thing" - a judgment that the FAA making these rules was "wrong.". I don't make that kind of moral judgment about the rules the FAA chooses to make about logging time toward certificates, ratings, privileges and currency, even when I disagree with them.

If I had to, I'd probably say that, even though I am a proponent of pilots building "real" cross country time after the private certificate, allowing instrument students to build toward the 50 hours of cross country PIC time required while training for the rating instead of forcing them to spend more money to rent an airplane to build it up solo is not a bad thing unless someone can show me evidence the current rule has compromised safety.

Mistake? Maybe maybe not. You think it is. The Chief Counsel made the first interpretation I'm aware of back in 1977, based, I think, on the 1973 wording of the regulation. I think if it was a mistake, the FAA has had 42 years to change it. That's all it takes. But the FAA has revised Part 61 almost in its entirely a few times and has corrected mistakes many times more. AFAIK, it's never even shown up in a proposed rule.

 

[kayoh190]

Yep. If he does take the job he’ll probably just log it as SIC. He would upgrade in less than a year anyway and the plane only flies 400 hours between 3 crews so he’s not building a whole lot of turbine PIC

Yeah, compared to the whole it's just not a lot of time - especially compared to the rate airline pilots fly. So I don't see the point in risking ****ing off an employer over a handful of hours.

 

[dtuuri]

I'm only saying "wheels came off" sounds like a "bad thing" - a judgment that the FAA making these rules was "wrong.". I don't make that kind of moral judgment about the rules the FAA chooses to make about logging time toward certificates, ratings, privileges and currency, even when I disagree with them.

Without dropping the "or"--there was no need of an interpretation. You logged it as Dual or PIC/Solo. After the interpretation changed the original meaning, rules were amended to reflect the change.

If I had to, I'd probably say that, even though I am a proponent of pilots building "real" cross country time after the private certificate, allowing instrument students to build toward the 50 hours of cross country PIC time required while training for the rating instead of forcing them to spend more money to rent an airplane to build it up solo is not a bad thing unless someone can show me evidence the current rule has compromised safety.

Ok, in the 1960s you had to have a commercial license to get an instrument rating or be a private with 200 hours TT of which 100 was PIC of which 50 was cross country. That TT standard was dropped to 125 hours, IIRC. Now it's even lower, just the 50 cross country PIC, right? On top of that the rule expressly permits the PIC time to be satisfied with instruction received time:

(g) An applicant for a combined private pilot certificate with an instrument rating may satisfy the cross-country flight time requirements of this section by crediting:

(1) For an instrument-airplane rating or an instrument-powered-lift rating, up to 45 hours of cross-country flight time performing the duties of pilot in command with an authorized instructor;​

The original standard has been watered down, for better or worse (I care not), but the rule makes an exception for this narrow purpose of an instrument rating. Doesn't the exception prove the rule, i.e., that normally PIC experience isn't gained when accompanied by an instructor? And doesn't the rule imply the caveat that the student instrument pilot be the one performing the duties of the PIC, meaning the CFI doesn't, ever, intervene?

 

[jordane93]

Yeah, compared to the whole it's just not a lot of time - especially compared to the rate airline pilots fly. So I don't see the point in risking ****ing off an employer over a handful of hours.

It seems like a fun gig. Lots of international stuff, coast to coast. Pay is on par with what he would make at 9E and he would get some management experience which is what he wants. The only downside is the lack of flying and he’s trying to build PIC time. I told him to stick it out here but that’s just what I would do.

 

[kayoh190]

The only downside is the lack of flying and he’s trying to build PIC time. I told him to stick it out here but that’s just what I would do.

Yeah, if someone is trying to get to a major ASAP, sticking it out at a regional is probably the correct move. That said, there are a lot of guys out there that are willing to sacrifice future seniority to get the opportunity to experience different segments of the industry, and I can't argue with that mentality either. I flew corporate/charter for 6 years, and although I consider airline flying to be the right place for me now, the corporate and charter gigs gave me an opportunity to experience and see things that simply don't exist on the 121 side. So it wasn't the fastest path to where I currently am, but I don't have any regrets either.

Now that said, your razor sharp focus will likely get you hired almost a decade younger than I was when I got my gig, resulting in hundreds of thousands if not seven figures worth of additional career earnings, so don't think I'm throwing shade either!

 

[midlifeflyer]

On top of that the rule expressly permits the PIC time to be satisfied with instruction received time:

(g) An applicant for a combined private pilot certificate with an instrument rating may satisfy the cross-country flight time requirements of this section by crediting:

(1) For an instrument-airplane rating or an instrument-powered-lift rating, up to 45 hours of cross-country flight time performing the duties of pilot in command with an authorized instructor;​

***
Doesn't the exception prove the rule, i.e., that normally PIC experience isn't gained when accompanied by an instructor?

I guess it does. But not the "rule" you are claiming. I highlighted the part you didn't.

The applicant for a private certificate combined with an instrument rating is a student pilot. Student pilots may only log PIC time when solo. It has nothing to do with a private pilot seeking an instrument rating. Basically the rule you cite levels the requirements between a student pilot seeking an instrument rating and a private pilot seeking an instrument rating. Basic private pilot certificate requires 5 hours student solo cross country, so we are talking about all of the additional 45 - the number in the rule you cite.

The private-to-instrument applicant can fulfill the additional 45 hour cross country requirement with solo or dual flight since logging PIC is authorized when the sole manipulator is a rated pilot, whether or not a CFI is on board. OTOH, the student pilot can only log PIC time when solo; he can't log PIC on a dual flight. I see the FAA ding little more than using the familiar "substitute solo" to help level the field for the combined applicant so the combined applicant doesn't have to do 45 hours of additional solo cross country flight, while the private pilot can combine solo and instruction. I guess the FAA could have done it a number of ways. It chose the familiar "substitute solo" route.

In either case, the minimum requirement ends up the same. 5 hours which has to be solo cross country; 45 hours which can either be solo or with an instructor.

 

[Greg Bockelman]

Yeah, compared to the whole it's just not a lot of time - especially compared to the rate airline pilots fly. So I don't see the point in risking ****ing off an employer over a handful of hours.

It’s all in the presentation.

 

[dtuuri]

I guess it does. But not the "rule" you are claiming. I highlighted the part you didn't.

The applicant for a private certificate combined with an instrument rating is a student pilot. Student pilots may only log PIC time when solo. It has nothing to do with a private pilot seeking an instrument rating. Basically the rule you cite levels the requirements between a student pilot seeking an instrument rating and a private pilot seeking an instrument rating. Basic private pilot certificate requires 5 hours student solo cross country, so we are talking about all of the additional 45 - the number in the rule you cite.

The private-to-instrument applicant can fulfill the additional 45 hour cross country requirement with solo or dual flight since logging PIC is authorized when the sole manipulator is a rated pilot, whether or not a CFI is on board. OTOH, the student pilot can only log PIC time when solo; he can't log PIC on a dual flight. I see the FAA ding little more than using the familiar "substitute solo" to help level the field for the combined applicant so the combined applicant doesn't have to do 45 hours of additional solo cross country flight, while the private pilot can combine solo and instruction. I guess the FAA could have done it a number of ways. It chose the familiar "substitute solo" route.

In either case, the minimum requirement ends up the same. 5 hours which has to be solo cross country; 45 hours which can either be solo or with an instructor.

ah-Ha! I misread that it was a student applying. Anyway, it doesn't change the fact that these kinds of questions, other than "Can you log copilot time in a Cessna 150?" never came up in the 1960s. Now there's an endless number of scenarios and confusion since the "or" was dropped from line 3 with no explanation or debate. It just vanished and confusion arrived.

 

[midlifeflyer]

ah-Ha! I misread that it was a student applying. Anyway, it doesn't change the fact that these kinds of questions, other than "Can you log copilot time in a Cessna 150?" never came up in the 1960s. Now there's an endless number of scenarios and confusion since the "or" was dropped from line 3 with no explanation or debate. It just vanished and confusion arrived.

Blame the Internet. I doubt logging questions were discussed at all until at least Usenet, at least not extensively. As recently as 10 years ago, you would still find many, many folks who insisted one must act as PIC to log PIC - including those who have always been pilots under the "new" rules. They, especially some great instructors - still believe it. It's just lack of exposure - they don't hang out in online forums and their teaching allows CFI renewal without an FIRC (where the logging rules became a target subject).

 

[dtuuri]

Blame the Internet. I doubt logging questions were discussed at all until at least Usenet, at least not extensively. As recently as 10 years ago, you would still find many, many folks who insisted one must act as PIC to log PIC - including those who have always been pilots under the "new" rules. They, especially some great instructors - still believe it. It's just lack of exposure - they don't hang out in online forums and their teaching allows CFI renewal without an FIRC (where the logging rules became a target subject).

I can remember where I was when I first heard of the first interpretation just the same as when Kennedy was shot and the Space Shuttle blew up. Just can't remember the year. Could have been 1973 through--you say 1977. It was a real shock. I was standing in the lobby of the FBO where I used to instruct listening to another instructor tell the story. First time I had ever heard of the Chief Counsel. To this day my logbooks don't show PIC time if I was receiving instruction and no safety pilot time at all. Adding PIC column totals to Dual and SIC equals Total time. I like the nice clean look of it.

 

[midlifeflyer]

I can remember where I was when I first heard of the first interpretation just the same as when Kennedy was shot and the Space Shuttle blew up. Just can't remember the year. Could have been 1973 through--you say 1977.

1977 is just the first one I've seen. My access to older interpretations starts in 1975. Whether there even were formal interpretation letters from the Chief Counsel prior to then, I have no idea.

At the time, the reg said, "A private or commercial pilot may log as pilot in command time only that flight time during which he is the sole manipulator of the controls of an aircraft for which he is rated, or when he is the sole occupant of the aircraft, or when he acts as pilot in command of an aircraft on which more than one pilot is required under the type certification of the aircraft, or the regulations under which the flight is conducted." I know that language (pretty much the same as the current language) appeared in an FAR revision in 1973. The proposed rule was 1971.1973 was a "revision" of Parts 61 and 91, so something appeared, but the Final Rule does not specify whether this language was an addition or a change or carried over from a prior version. Is it possible what you recall is discussions over the 1971 proposals?

AFAIK, the language does not appear prior to the FAR. The 1954 CAR didn't define "pilot in command" for logging purposes, so I assume it was referring to "real" pilot in command for logging purposes.

PS - Dave, you probably realize at this point, this is pretty much a private conversation., right?

 

[Tantalum]

following the flow chart

Do not show @EdFred that chart!

it's also going to depend on whether or not the plane is in actual or simulated conditions (or both) and whether or not someone is wearing foggles

Okay sorry, return to your regularly scheduled programming

 

[dtuuri]

At the time, the reg said, "A private or commercial pilot may log as pilot in command time only that flight time during which he is the sole manipulator of the controls of an aircraft for which he is rated, or when he is the sole occupant of the aircraft...

That much of the rule existed in 1970 (I'm holding a copy) and so did the "or" in the "type of piloting time" paragraph. In today's context the two would be inconsistent, but it made sense then because single engine rated pilots could solo multiengine airplanes without a class rating. Therefore, both elements were consistent with the either/or logging requirement.

Is it possible what you recall is discussions over the 1971 proposals?

No it wasn't about a proposal. It may not have been an "interpretation" though. I thought the story was about somebody suing for the right to log the time and a judge agreed, but in retrospect I may have misunderstood and it was really a Chief Counsel pronouncement.

PS - Dave, you probably realize at this point, this is pretty much a private conversation., right?

Heh. If it goes any further, you'll be talking to yourself.